Support Documents for 

Significant New Use Rule (SNUR) on 

Premanufacture Notice (PMN) 

P-10-290 

EPA Docket EPA-HQ-OPPT-2011-0577 

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Index

A-001 Structure Activity Team (SAT) Report for 

PMN P-10-290 

A-002 Initial Review Engineering Report for 

PMN P-10-290 

A-003 Initial Review Exposure Report for 

PMN P-10-290 

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A-001 

Structure Activity Team (SAT) Report

for PMN P-10-290 

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A-002 

Initial Review Engineering Report

for PMN P-10-290 

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TEST DATA REVIEW ENGINEERING REPORT

P-10-0290

Post-Focus Draft Revision 3 7/19/2010

ENGINEER: Arnold \ BCS

PV (kg/yr): 

Revision Notes/Assessment Overview:

SUBMITTER: Reichhold, Inc. (submitter)

USE:

OTHER USES:

MSDS: Yes LABEL: No

Gen Eqpt: Eng Controls: good general ventilation should be sufficient to control airborne levels of irritating 

vapors. Local ventilation may be required during certain operations. // Eye/Face: wear safety glasses with side 

shields and a faceshield or goggles and a faceshield. // Skin: gloves made of neoprene. Chemical resistant apron. 

boots.

Respirator: in case of insufficient ventilation wear suitable respiratory equipment.

Health Effects: Eye: mild eye irritant. // Skin: Mild skin irritant. Repeated exposure may cause skin dryness or 

cracking. // Inhalation: vapors and/or aerosols which may be formed at elevated temperatures may be irritating to 

eyes and respiratory tract. // Ingestion: swallowing may irritate the mouth, throat, and stomach. Ingestion is not an 

anticipated route of exposure for this material in industrial use.

TLV/PEL: - none established

CRSS: (3/29/2010):

Chemical Name:

S-H2O: 0.00276 g/L @ 

VP: 1.0E-6 torr @ 

MW: 

Physical State and Misc CRSS Info:

Neat: Liquid (Est.) Mfg: 

Proc/Form: End Use: 

Submitted Data: WS = Insoluble; Specific Gravity = 1.08-1.12; Flash Point > 93 °C. Estimated Data: 

BP = 487 °C (EPI); VP = 5.8E-8 torr (EPI); WS = 0.00276 g/L (EPI); logP = 4.62 (EPI). The EPI estimations were 

performed for the

Consumer Use: No

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SAT (concerns): (3/30/2010):

Related Cases and Misc SAT Info:

Migration to groundwater: Negligible

PBT rating: P2 B1 T1 .

Health: 1-2, Dermal, Inhalation

Eco: 3, Water (All releases to water with a CC = 8 ppb)

OCCUPATIONAL EXPOSURE RATING: 2-3B

NOTES & KEY ASSUMPTIONS:

Generated by the 06/07/2005 version of ChemSTEER. 

 

POLLUTION PREVENTION CONSIDERATIONS:

P2 Claim: 

P2 REC:

EXPOSURE-BASED REVIEW: 

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P-10-0290

PROC/USE: 

Number of Sites/Location: 

 

Basis:

Process Description:

ENVIRONMENTAL RELEASES ESTIMATE SUMMARY

IRER Note: The daily releases listed for any source below may coincide with daily releases from the other sources

to the same medium. 

Output 2: 

to: 

from: 

basis:

Conservative: 

to: 

from: 

basis:

High End: 

to: 

from: 

basis:

Output 2

to: 

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from: Coating Using Hand-Held Spray Gun

basis:

RELEASE TOTAL

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes:

Dermal:

Exposure to

High End: 

Number of workers (all sites) with Dermal exposure

Basis: 

Inhalation:

Exposure to

Upper Bound: 

Number of workers (all sites) with Inhalation exposure:

Basis: 

INHALATION MONITORING DATA REVIEW

1) Uncertainty (estimate based on model, regulatory limit, or data not specific to industry): Yes

2) (a) Exposure level > 1 mg/day? Yes

 (b) Hazard Rating for health of 2 or greater? No

Inhalation Monitoring Data Desired? No

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P-10-0290

MFG: 

Number of Sites/Location: 

Basis:

Process Description:

ENVIRONMENTAL RELEASES ESTIMATE SUMMARY

IRER Note: The daily releases listed for any source below may coincide with daily releases from the other sources

to the same medium. Note, SAT concerns for dermal, inhalation, and releases to water with CoC = 8 ppb. 

Incineration releases < 28,000 kg/site-day; air releases negligible (VP < 0.001 torr); migration to groundwater = 

negligible; releases to water are possible due to the unclear releases media from equipment cleaning.

Conservative: 

to: 

from: 

basis: 

Output 2: 

to: (submission)

from: 

basis:

RELEASE TOTAL

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes:

Dermal:

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Exposure to 

High End: 

Number of workers (all sites) with Dermal exposure:

Basis: 

Dermal:

Exposure to 

High End: 

Number of workers (all sites) with Dermal exposure:

Basis: .

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A-003 

Initial Review Exposure Report

for PMN P-10-290 

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POST FOCUS EXPOSURE REPORT 

Updated according to updated engineering report, Post-Focus Draft Revision 3, 

7/19/2010. 

 Chemical ID: P-10-0290 Reviewer: Delpire/SS 

 

 

Results Table: Dose, Concentration, and Days Exceeded Results Summary 

Exposure Scenario1 Water Landfill Stack Air Fugitive Air 

Drinking Water Fish Ingestion 

ADR LADD ADR LADD 7Q104 

CC = 8 

PDM 

Days 

Exceeded 

LADD ADR LADD ADR LADD 

Release 

activity(ies)2; 

exposure 

calculation(s)3 

mg/kg/day m g/kg/day mg/kg/day mg/kg/day μg/l # Days mg/kg/day m g/kg/day mg/kg/day m g/kg/day mg/kg/day 

PROC/USE: Max 

ADR 

--- --- --- 

PROC/USE: Max 

LADD 

--- --- --- 

1 Exposure scenario titles consist of release activity followed by exposure calculation abbreviation. 

2 Release activities are from engineering report's Manufacturing (Mfg), Processing (Proc) and Use release activity 

labels.Multiple release activities are combined in one exposure scenario if their releases occur at same location. 

3 Exposure calculations are Acute Dose Rate (ADR), Lifetime Average Daily Dose (LADD), and Probabilistic 

Dilution Model (PDM). There may be one, two, or all three exposure calculations per exposure scenario. CC is the 

aquatic concentration of concern. 

4 This column displays concentration values for the 7Q10 streamflow, which is defined as the average daily 

streamflow of the seven consecutive days of lowest flow within a ten year period. 

Remarks: 

Results Table: Exposure Based (XB)/Persistent (P2B2) Criteria 

Fate test recommendations?: (default is NA)

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 POST FOCUS EXPOSURE REPORT 

Chemical ID: P-10-0290 Assessor: Delpire/SS 

ENVIRONMENTAL RELEASES 

 Scenario#:1 Number of Release Sites: 

 Release Activity: PROC/USE: Max ADR 

 Release Description: WATER LANDFILL 

Non- 

 (k

 

 

 N/A/0

 (kg

 

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POST FOCUS EXPOSURE REPORT 

Chemical ID: P-10-0290 

INHALATION EXPOSURE ESTIMATES (POST-TREATMENT) 

SCENARIO #: 1 RELEASE ACTIVITY:PROC/USE: Max ADR 

RELEASE DESCRIPTION: 

METHOD OF CALCULATION: Screen3 

EXPOSED POPULATION: Adult 

Number of Sites: 

Per Site Fugitive Release: 15.00 kg/site/day 

Fugitive Release Days per Year: days 

% Removal via Fugitive Release: 0.00 % 

Total Fugitive Release: kg/yr 

Max Annual Average Air Concentration 

(Fugitive): 

110.00 μg/ m3

Max 24 Hour Average Air 

Concentration(Fugitive): 

2050.00 μg/ m3

Per Site Stack Release: NA kg/site/day 

Stack Release Days per Year: NA days 

% Removal via Stack Release: 99.90 % 

Total Stack Release: NA kg/yr 

Max Annual Average Air Concentration (Stack): 0.00 μg/m3

Max 24 Hour Average Air Concentration (Stack): 0.00 μg/m3

ASSUMPTIONS 

Exposure Units 

Results 

(Stack) 

Results 

(Fugitive) ED 

(years) 

AT 

(years) 

BW 

(kg) 

Inh. Rate 

(m3/hr) 

Cancer 

LADDpot (mg/kg/day) 

LADCpot (mg/m3) NA 

Acute 

ADRpot (mg/kg/day) 

Inhalation Comments: 

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 Stack Parameter Data Fugitive Parameter Data 

Stack Height 10.00 Release Height: 3.00 m 

Inside Stack 

Diameter: 

0.10 Length of Release 

Opening: 

10.00 m 

Stack Gas Exit 

Velocity: 

0.10 Width of Release 

Opening: 

10.00 m 

Stack Gas 

Temperature: 

293.00 

 

 Meteorological and Terrain Information: 

Surrounding Land Use: Rural 

Terrain Height: 0.00 m 

Distance to Residence of Interest: 100.00 m 

Meteorological Class: Full 

Stability Class: NA 

Wind Speed: NA 

 

 Do wnwash Information: 

Facility Length: NA m 

Facility Width: NA m 

Facility Height: NA m 

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 POST FOCUS EXPOSURE REPORT 

Chemical ID: P-10-0290 Assessor: Delpire/SS 

ENVIRONMENTAL RELEASES 

 Scenario#:2 Number of Release Sites: 

 Release Activity: PROC/USE: Max LADD 

 Release Description: WATER LANDFILL 

Non-sludge/Sludge 

STACK FUGITIVE 

Total Releases: 

 (k g/yr) (kg/yr) (kg/yr) (kg/yr) 

 

 Non-sludge/Sludge 

Release Days/yr: 

Per Site Release: 

 (kg /site/day) (kg/site/day) (kg/site/day) (kg/site/day) 

Remarks: 

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POST FOCUS EXPOSURE REPORT 

Chemical ID: P-10-0290 

INHALATION EXPOSURE ESTIMATES (POST-TREATMENT) 

SCENARIO #: 2 RELEASE ACTIVITY:PROC/USE: Max LADD 

RELEASE DESCRIPTION: 

METHOD OF CALCULATION: Screen3 

EXPOSED POPULATION: Adult 

Number of Sites: 

Per Site Fugitive Release: 3750.00 kg/site/day 

Fugitive Release Days per Year: days 

% Removal via Fugitive Release: 0.00 % 

Total Fugitive Release: kg/yr 

Max Annual Average Air Concentration 

(Fugitive): 

110.00 μg/ m3

Max 24 Hour Average Air 

Concentration(Fugitive): 

N/A μg/m 3

Per Site Stack Release: NA kg/site/day 

Stack Release Days per Year: NA days 

% Removal via Stack Release: 99.90 % 

Total Stack Release: NA kg/yr 

Max Annual Average Air Concentration (Stack): 0.00 μg/m3

Max 24 Hour Average Air Concentration (Stack): N/A μg/m3

ASSUMPTIONS 

Exposure Units 

Results 

(Stack) 

Results 

(Fugitive) ED 

(years) 

AT 

(years) 

BW 

(kg) 

Inh. Rate 

(m3/hr) 

Cancer 

LADDpot (mg/kg/day) 

LADCpot (mg/m3) NA 

Acute 

ADRpot (mg/kg/day) 

Inhalation Comments: 

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 Stack Parameter Data Fugitive Parameter Data 

Stack Height 10.00 Release Height: 3.00 m 

Inside Stack 

Diameter: 

0.10 Length of Release 

Opening: 

10.00 m 

Stack Gas Exit 

Velocity: 

0.10 Width of Release 

Opening: 

10.00 m 

Stack Gas 

Temperature: 

293.00 

 

 Meteorological and Terrain Information: 

Surrounding Land Use: Rural 

Terrain Height: 0.00 m 

Distance to Residence of Interest: 100.00 m 

Meteorological Class: Full 

Stability Class: NA 

Wind Speed: NA 

 

 Do wnwash Information: 

Facility Length: NA m 

Facility Width: NA m 

Facility Height: NA m 

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